Rahul Seth v. ACIT (2021) 91 ITR 34 (SN) (Delhi)(Trib.)

S. 153A : Assessment-Search or requisition-Unabated assessment No material relating to addition found in search-Addition not sustainable. [S. 132, 143(3)]

Held that the assessments having not abated, the scope of proceedings under section 153A of the Act had to be confined to material found in the course of search. No bank statement was found or seized during the course of search. Since no material on the basis of which the addition has been made was found in the course of search, the additions made by the Assessing Officer in the order of assessment could not have been subject matter of proceedings under section 153A of the Act. (AY. 2006-07, 2007 08)